Last updated on: 01/12/23
This Privacy Notice provides information on the collection, use, sharing and further processing of personal information by WHALEY TECH LTD. WHALEY TECH LTD and its affiliates (hereinafter referred to as "WHALEY"). This Privacy Notice also explains the choices you have in relation to these processing activities and your relevant rights in this respect. This Privacy Notice applies as far as the processing activities are not subject to other privacy policies, are evident from the circumstances or are provided for by applicable law. As used in this Privacy Notice, ‘personal information’ or ‘personal data’ means any information that relates to an identified or identifiable individual, for example your name, address, email address, business contact details, or information collected through your interactions with us via our websites, at events or otherwise.
The personal data you provided for the stated purposes will be handled with confidentiality and utilized exclusively in the context of transactions between you and WHALEY. In compliance with Chapter III, Sections 1 to 5, Articles 12 - 23, of the EU General Data Protection Regulation (GDPR), we inform you that we will retain personal data as it pertains to our business association with you. Rest assured that the details you provide will not be disclosed or sold to any external parties or entities not affiliated with WHALEY.
This Privacy Notice applies in connection with your use of our websites, mobile applications, online tools, social media, agreements, general terms and conditions or by way of other means that link to this Privacy Notice, your interactions with us during personal meetings or at group events, and in connection with other offline sales, services, marketing activities and other business relation-ship activities with WHALEY.
We may provide links to other websites and applications (e.g. social media websites). Please note that our browsing and interaction on any other website is subject to the terms of use and privacy policies and notices of such third-party websites. This Privacy Notice applies only to the website and services of WHALEY as set forth in this Privacy Notice and not to other websites or applications operated by third parties where we do not control the privacy practices of such other websites or applications. We strongly encourage you to read the terms of use and privacy policies and notices of other websites carefully before providing personal data through that website. We are not responsible or liable for the privacy practices, information or content of such third-party websites.
Data protection notice applies for the website, social media presences, applicants and employees of WHALEY and group-affiliated companies (hereinafter referred to as WHALEY) and for the sending of e- mails by WHALEY.
In order to inform you about our policies and activities regarding the collection, use and disclosure of personal data on the Internet, WHALEY provides this policy in electronic form. This Policy applies to all websites owned or operated by WHALEY, its affiliates, subsidiaries and/or companies directly or indirectly controlled by WHALEY, applicants and employees, as well as appearances on various social media platforms. It does not apply to websites that have their own privacy policy. The website you are currently using is hereinafter referred to as the "Website".
The Website and the social media presences serve to provide information about WHALEY’s services and about WHALEY as an employer. Through the Website and the social media appearances, individuals also have the opportunity to contact WHALEY.
Personal data is processed in connection with the website, the offers provided on the website, the social media appearances and the sending of emails.
Below you will find information about the company responsible for processing your personal data, its representative and the data protection officer, as well as your rights in relation to the processing of your personal data.
Below you will also find information about the processing of your personal data with the website, the offers provided on the website and the sending of emails for event invitations, offers and information about WHALEY and its companies belonging to the group, such as BAK DOOEL 2021.
In this policy, the term "personal data" refers to data that relates to an individual and identifies that individual either directly or indirectly (in conjunction with other information that may come into WHALEY's possession), such as your name, email address or telephone number, particularly in connection with job applications.
WHALEY TECH LTD, 128 City Road, London EC1V 2NX, United Kingdom
When you visit this website, we do not collect any personal data from you. Personal data is only collected if you provide it to us yourself via our contact form. This data will only be used to answer your request and will then be deleted. Most of our services do not require registration. This means you can visit our website without telling us who you are.
To access some areas of our website, e.g. to apply for a job, we may require personal data from you. In these cases, the entry of personal data is voluntary, and you will be expressly requested to provide this personal data and informed about the intended use of this personal data.
Communication with you. We will respond to any comments or requests you submit to us through our website, such as online inquiries, comments, or conference registration. This may mean that we call or email you.
Your personal information will be stored on our systems accordingly.
The following table lists the categories of personal data that WHALEY processes or could process as part of the processing activities described in this global privacy statement.
Personal data: Name, preferred gender pronoun, contact information of any kind (such as email, phone numbers, address), gender, date of birth, age, place of birth.
Audiovisual: photographs and images/recordings taken with CCTV or other video systems, as well as voice recordings.
Position: description of current position, job title, employer, location, WHALEY contact(s).
In addition, WHALEY may process the personal data listed in the table below for recruitment purposes.
Personal Data: In addition to the personal data listed above, WHALEY may collect other personal data for recruitment purposes, such as national identification number, social security number, insurance information, marital/partnership status, domestic partners, relatives, emergency contacts, military service.
Confidential Data: WHALEY may collect certain types of confidential sensitive information when permitted by applicable local law or when you have consented to it, such as health/medical information (including disability), information about union membership, religion, race or ethnicity, minority flag, and (to the extent permitted by law) information about criminal convictions and offenses. WHALEY collects this information for certain purposes, such as health/medical information to treat and provide care for a disability or illness; background checks; religious or church affiliation in countries such as Germany where such information is required for legal tax deductions; and personal diversity information (such as race or ethnicity) to comply with legal obligations and internal policies related to diversity and equal treatment.
Immigration Data: WHALEY may collect citizenship, passport, residence or work permit information (physical copy and/or electronic copy).
Talent Management Information: information required for a background check, details of performance decisions and outcomes, performance feedback and alerts, e-learning/training programs, performance and development reviews (including information you provide when requesting/providing feedback, prioritizing and updating your inputs into relevant tools), driver's license and vehicle registration, and biographical information.
As indicated in the Global Privacy Policy, WHALEY processes your personal data for a variety of purposes. The following table lists each of the purposes for which WHALEY processes your personal data.
Facilitating communication with you (including in emergency situations): Facilitating communication with you, ensuring business continuity, protecting the health and safety of employees and others, protecting IT infrastructure, office equipment and other assets, facilitating communication with you and emergency contacts you provide.
Regulatory Compliance: meeting legal requirements, e.g., legal submission, accounting and reporting requirements, conducting audits, approving government audits and meeting other requirements of government or public agencies, participating in legal proceedings, e.g. in subpoenas, pursuing legal claims and remedies, defending litigation and resolving internal complaints or claims, conducting investigations and complying with internal policies and procedures, protecting, enforcing or defending WHALEY's legal rights, privacy rights, security or property, WHALEY affiliates or their employees, agents and contractors (including the enforcement of relevant agreements and terms of use), protecting the data security, privacy and safety of users of WHALEY products or services or the public, protecting against fraud, or policies for risk management purposes.
Tracking your use of WHALEY's property: monitoring activities in accordance with the laws of the land and/or applicable WHALEY policies (including monitoring the use of WHALEY resources).
Recruitment: managing applications, including conducting interviews and appraisals, performance appraisals, financial planning, administering payments, managing inclusion and diversity programs, conducting background checks, scheduling and monitoring training requirements.
WHALEY is a global organization. We have various legal entities (e.g., national subsidiaries) and partners in Switzerland, certain EU member states and other European countries. Our internal processes and infrastructures are therefore international in nature and scope.
Accordingly, you should be aware that we may share your personal data with third parties to process it on our behalf. We require that third parties handle the personal data they receive in accordance with WHALEY's privacy and security policies.
Your personal data may therefore also be subject to cross-border transfer. Cross-border transfer of your personal data will only occur (i) to countries with equivalent data protection standards or (ii) on the basis of officially recognized data protection agreements or (iii) on the basis of officially recognized standard data protection clauses.
In case you declared your consent for the processing of certain personal data by the Group, you have the right to withdraw your consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal.
Most of the personal information we collect and use for marketing purposes relates to individual employees of our customers and other companies with whom we have an existing business relationship. We may also obtain contact information from public sources, including content posted on social media sites, to make initial contact with a relevant individual at a customer or other business.
We send commercial emails to individuals at our customers or other companies with whom we wish to establish or maintain a business relationship, in accordance with applicable marketing laws.
Like most companies, WHALEY uses Customer Relationship Management (CRM) database technology to manage and track our marketing efforts. Our CRM databases contain personal information that belongs to individuals at our clients and other companies with whom we already have a business relationship or wish to establish one.
Personal data used for these purposes includes relevant business information such as: Contact information, publicly available information (e.g., board membership, published articles, press releases, your public posts on social media sites when relevant to the business purpose), your responses to targeted emails (including web activity following links in our emails), website activity from registered users of our website, and other business information recorded by WHALEY professionals based on their personal interactions with you. If you wish to be excluded from our CRM databases, please contact us.
We may combine data from publicly available sources and from our various email, website, and personal interactions with you (this includes information collected through our various websites, such as our career and corporate websites, and information collected when you register or log in to our websites or connect to our websites using your social media credentials (such as LinkedIn)). We combine this data to better assess your experience with WHALEY and to carry out the other activities described in our Privacy Policy.
We may share personal data with our service providers, professional advisors, public and government authorities, or third parties in connection with a (potential) corporate or commercial transaction. These third parties may be located in other countries. Before doing so, we will take the necessary steps to ensure that your personal data is adequately protected as required by relevant data protection laws and WHALEY's internal policies.
Unless you are notified otherwise, transfers of your personal data from the European Economic Area (EEA) to third parties outside the EEA will be made on the basis of an adequacy decision or in accordance with standard contractual clauses. All other transfers of your personal data outside the EEA will be made in accordance with the relevant international data transfer mechanisms and standards.
You may exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal information or by using opt-out mechanisms in the emails we send you. You may also exercise your right to stop receiving marketing communications or to delete your personal information from our CRM databases by contacting us. In this case, we will retain a minimum amount of personal data to note that you have unsubscribed so that we do not need to contact you again. Alternatively, you may email us at info@whaley.ai to notify us of your unsubscribe request.
If you have any questions about data privacy or would like to provide us with permissions for websites or promotional purposes, please contact us.
In addition to the information above, this section tells you how we use personal information when you visit WHALEY's offices.
This information also refers to the possible processing of your personal data by video surveillance and access control systems, if such systems are active.
When you enter our business premises, personal data such as your surname, first name and, if applicable, employer, as well as your time of arrival and departure and Video recording at the entrance are collected. This is based on project-specific requirements that have an increased security level and make this documentation necessary. This data is also generally stored for 12 months.
If you would like more information about this, please contact us at the address you provided.
WHALEY does not generally collect "particularly sensitive personal data". "Particularly sensitive personal data" is personal data about race, political opinion, religious or philosophical beliefs, trade union membership, health or sex life. By voluntarily providing us with particularly sensitive personal data (e.g., by submitting your resume or applying for a job online), you expressly consent to the use of your personal data as described in this policy.
WHALEY is a global organization. We have various legal entities (e.g., national subsidiaries) and partners in Switzerland, certain EU member states and other European countries. Our internal processes and infrastructures are therefore international in nature and scope.
Accordingly, you should be aware that we may share your personal data with third parties to process it on our behalf. We require that third parties handle the personal data they receive in accordance with WHALEY's privacy and security policies.
Your personal data may therefore also be subject to cross-border transfer. Cross-border transfer of your personal data will only occur (i) to countries with equivalent data protection standards or (ii) on the basis of officially recognized data protection agreements or (iii) on the basis of officially recognized standard data protection clauses.
WHALEY stores your personal data only for as long as necessary. In addition, WHALEY maintains specific policies and procedures for the management and retention of records and data so that personal information is deleted after a reasonable period of time in accordance with the following retention criteria:
WHALEY will retain your personal information for as long as we have a business relationship with you.
WHALEY will retain your personal information for as long as it is necessary to comply with a legal obligation.
WHALEY will retain your personal information for as long as necessary to maintain or improve WHALEY's legal position (e.g., in relation to statutes of limitations, litigation or government investigations).
Please keep your personal information up to date and notify WHALEY of any material changes to your personal information.
WHALEY implements appropriate technical and organizational security measures to protect your data managed on our systems against accidental or intentional tampering, loss, or access by unauthorized persons. The security measures are subject to continuous improvement in line with technological developments. We take the appropriate technical and organizational security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized use, disclosure or access, in particular where processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse. In the event personal data is compromised as a result of a Personal Data Breach we will make the necessary notifications, as required under applicable laws.
Information presented on WHALEY’s websites may mention products and services that have not been announced or may not be available in your country. This information does not indicate WHALEY’s intention to offer these products and services in your country. For details on product and service availability, please reach out to our regional distributor or representative, who will be happy to provide information.
The brand names used on WHALEY’s websites are either owned by WHALEY or third parties with proprietary rights. These brand names should not be used without the consent of the relevant rights holders. WHALEY retains all rights to the information and the design of its websites. The responsible handling of your data and compliance with all applicable national and international privacy policies are priorities for WHALEY.
We may amend this privacy policy at any time without prior notice. The current version published on our website applies.
If you have any questions about this Data Privacy Policy or requests relating to the use of your personal data by WHALEY, you are welcome to contact us via the email address info@whaley.ai or on +44 20 4586 7886
We use the marketing automation software HubSpot of the American company HubSpot Inc., 25 First Street, Cambridge, MA 02141 USA (hereinafter "HubSpot") on our website on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our website in order to optimize it and provide you with the best possible and user-friendly service). HubSpot is an integrated software solution that we use to cover various aspects of our digital marketing, sales and customer relationship management.
Contacting customers via the contact form.
Landing pages as part of promotional campaigns with options such as downloading whitepapers or similar content.
Social media linking and/or social media sharing.
Evaluation of the use of our websites (e.g. accesses, pages visited, session duration, etc.) as well as publications in social networks.
The content of our websites as well as your personal data, which you provide e.g. when using our contact form, are usually transferred to a server of HubSpot in the USA and stored there. HubSpot, Inc. has certified to the EU-U.S. and Swiss-U.S. Privacy Shield Framework administered by the U.S. Department of Commerce to implement appropriate protections for such transfers under Article 46 of the GDPR.
For more information about HubSpot's data use, settings, and opt-out options, please visit HubSpot's website: Privacy Policy, Cookie Policy, and Data Protection (GDPR).
WHALEY also uses the LinkedIn button, a social network of LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. You can share a post with LinkedIn via LinkedIn. When you use this service, your browser establishes a direct connection to LinkedIn. Unless you are on LinkedIn anyway, the content of the button is transmitted to your browser and integrated into the website.
WHALEY has no control over the data that LinkedIn collects or processes via this button. For the purpose and scope of the data collected and processed by LinkedIn as well as the data protection settings, please refer to LinkedIn's privacy policy.
You can also prevent the transmission of data to LinkedIn with a corresponding plugin for your browser. Sharing WHALEY's offer together with LinkedIn (e.g. "share") is then no longer possible.
All personal data, including the personal data contained in the attachments, which you provide to us via the applicant portal or by e-mail, will be collected, processed and used by WHALEY exclusively for the purpose of processing your application.
Your data will only be used by the respective company to fill the positions for which you have applied. They will not be passed on to other companies. If you have submitted a speculative application, we will consider your data for all current application procedures that fit your profile. The same applies in the event that you have given us your express consent to the further storage of your applicant profile after the conclusion of an application procedure.
We collect your personal data primarily to carry out the application process on the legal basis of § 6(1)(b), § 88 General Data Protection Regulation (GDPR) in conjunction with § 26(1) sentence 1(1) of the Federal Data Protection Act (old) (BDSG-alt). Further legal bases are § 6(1)(a) GDPR ("permission") and § 6(1)(f) GDPR ("balancing of interests"), e.g. for personnel evaluations and reporting. If the processing of personal data is necessary for compliance with a legal obligation to which the controller is subject, the legal basis is § 6(1)(c) GDPR.
If special categories of personal data are processed pursuant to Section 9(1) of the GDPR (e.g., health data), this is done on the basis of Section 9(2)(b) of the GDPR. In addition, the processing might be necessary to assess your ability to work in accordance with § 9(1)(h) GDPR.
In the case of an online application for a specific position or unsolicited applications, you enter your data in the relevant application form and upload the associated documents.
For e-mail applications, we record all relevant data in our applicant portal and upload your documents including your e-mail. Your e-mail will then be deleted from our mailbox. Please do not send applications by mail (paper applications), as we cannot process them for data protection reasons.
Your personal data will be treated as strictly confidential and will only be made available to the responsible parties involved in the application process. To ensure a smooth process, only selected WHALEY employees involved in the application procedure have access to your data.
In any case, your personal data will only be processed by the company responsible for the job posting and, if applicable, by service providers who are contractually and legally obligated to comply with the relevant data protection regulations. This does not apply in the event that you have submitted an unsolicited application or have given us your express consent to the further storage of your applicant profile after the conclusion of an application process (rejection or recruitment). In this case, we take your data into account for all ongoing application procedures, i.e. your personal data may be processed by different national companies. You can actively consent to the transfer of your personal data to individual or all country organizations. If you do not give or revoke this consent, your personal data cannot be considered for positions in these companies.
If you are hired, your data will be transferred from our applicant portal to our HR management systems. There, your data will be processed as employee data.
As a rule, your personal data will be deleted when processing is no longer necessary to make a decision on the establishment of an employment relationship. The duration of storage depends on the duration of the decision-making process.
If you apply online for a specific job and submit data to the applicant portal, you can access your data and the attachments (e.g. your CV) at any time and delete them yourself. You also have the option of asking us to delete your data. If you would like to have your applicant profile deleted immediately, please contact our data protection officer (see above).
Our standard deletion period for an application is six months after completion of the respective application process (rejection or recruitment). If we reject your application, we will inform you by e-mail that you can give your express consent to the further storage of your applicant profile after the conclusion of an application procedure. In this case, your applicant profile will be automatically deleted from the applicant portal twelve months after your last application has been deleted. The same applies to an applicant profile created as part of a speculative application.
If legal regulations, e.g. retention obligations, do not permit deletion, the processing of your data will instead be restricted (i.e. blocked) so that it is only accessible for compliance with mandatory legal requirements. This is also the case if there are indications that you will file claims against us. The data will be stored for as long as the processing of the data is necessary for the assertion, exercise or defense of legal claims.
According to Chapter IV, Section 4, Article 37, EU General Data Protection Regulation (EU-GDPR) WHALEY has designated a Data Protection Officer.
The Data Protection Officer is appropriately and promptly engaged in all matters pertaining to the safeguarding of personal data.
Name of Responsible Post:
WHALEY TECH LTD
Authorized Data Protection and Privacy Officer: Atanas Boshkov
Address of Responsible Post:
128 City Road, London EC1V 2NX
United Kingdom
info@whaley.ai
We make every effort to respond to inquiries promptly, but a reasonable processing time must be expected.
This policy was last updated on 1 st December 2023. Please visit this page regularly to see if this policy has changed.
In principle, you have the rights to information, correction, deletion, restriction, data portability, revocation and objection. If you believe that the processing of your data violates data protection law or that your data protection rights have been violated in any other way, you can complain to the supervisory authority.
You can reach us using the following contact details:
WHALEY TECH LTD
128 City Road, London EC1V 2NX
United Kingdom
info@whaley.ai
Your data is protected against unauthorized access by encrypted transmission, encrypted storage, a role and authorization concept, a data backup concept and physical security measures for the servers used. The transfer of your personal data to the servers is carried out according to the security standards of the TLS procedure.
For reasons of readability, the masculine form is chosen for personal designations; however, all personal designations stand for a gender-neutral designation. At WHALEY all people are welcome, regardless of gender, origin, sexual orientation and religion.
Despite careful control of the contents, we do not assume any liability for the contents of external links. The owner and or operators of the linked pages are solely responsible for their content.
Subcontractors and suppliers shall comply with applicable laws and regulations relating to their activities and the countries in which they conduct business. They shall respect intellectual property rights, conduct transfer of technology and know-how in a manner that protects intellectual property rights, and safeguard customer and supplier information.
We are committed to ensuring no modern slavery and human trafficking in our supply chains or any part of our business. We do not enter into business with any organization, which knowingly supports, or is found to be involved in slavery, servitude, or forced or compulsory labor.
We are committed to upholding our Anti-Corruption Policy and diligently following its principles to ensure ethical and transparent business practices.
Subcontractors and suppliers comply with the applicable legal requirements and effectively eliminate illegal employment.
Subcontractors and suppliers shall conduct their business in an environmentally responsible manner by ensuring compliance with relevant legal environmental requirements, standards and regulations and minimize environmental pollution. They are encouraged to include appropriate environmental and social considerations into the full lifecycle of their processes, technologies, products and packaging in order to enhance their business’ overall environmental performance and maximize opportunities for positive social impact.
Subcontractors and suppliers respect the health, safety, security and personal rights of their employees and adhere to the principles of respect, dignity, fairness and non-discrimination. They employ and remunerate their employees on the basis of fair and compliant contracts. They maintain applicable legal minimum labor and wage standards. They shall ensure normal working hours comply with national legislation or the prevailing industry standards. They shall commit to high standards of health and safety in their operation.
Subcontractors and suppliers forbid gifts to private or public officials that aim to influence business decisions or otherwise encourage them to act contrary to their obligations. Subcontractors and suppliers respect the privacy and confidential information of all their employees and business partners. Subcontractors and suppliers implement an appropriate Compliance Management System, with a scope that is related to the content of this Code which facilitates compliance with applicable laws, regulations, and standards.
a. WHALEY expects from its subcontractors and suppliers to communicate to their own employees, subcontractors and suppliers in order to ensure these principles are integrated into their operations.
b. Subcontractors and suppliers of WHALEY are required to report their own violations of this Code, insofar as these affect their business relations with WHALEY. They are also asked to report any knowledge of misconduct on the part of WHALEY employees.
c. Subcontractors and suppliers are required to actively resolve any suspicious cases and to cooperate unconditionally with WHALEY in this regard. If there are reasonable grounds to believe that a subcontractor or supplier has violated this Code or if a subcontractor or supplier, when a suspicious case arises, fails to sufficiently meet his obligations to resolve the case and to cooperate, WHALEY, on the basis of existing contractual or legal rights, can end all business relations with the subcontractor or supplier with immediate effect. In the event of a violation of this Code, WHALEY retains the right to initiate further legal measures, particularly damage claims.
d. WHALEY, from time to time, can appropriately update this Code and expects that its subcontractors and suppliers accept any such changes.
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